INDIAN BAR ASSOCIATION

(THE ADVOCATES’ ASSOCIATION OF INDIA)

Regional Office: Office No. 2 & 3, Kothari House, A. R. Allana Marg, Fort, Mumbai-23,
Maharashtra (India), Website: www.indianbarassociation.in
Contact us: dipaliojha@indianbarassociation.in

January 5, 2022
MOST URGENT & MOST SERIOUS

Subject: 1. To follow the law of ‘Informed Consent’ and to

fix the liability upon school Authority, Principal etc.
who are violating the law and forcing the children to
take experimental corona vaccines and thereby putting
their life in danger.

Reference: (i) Hon’ble Supreme Court Judgment Common

Cause Vs. Union of India (2018) 5 SCC 1.

(ii) Registrar General, High Court of Meghalaya

Vs. State of Meghalaya 2021 SCC OnLine Megh
130.

(iii) Re Dinthar Incident Vs. State of Mizoram 2021

SCC OnLine Gau 1313.

(iv) Master Haridan Kumar Vs. UOI 2019 SCC

OnLine Del 11929.

(v) Section 52, 304-A, 115, 120(B), 34, 109, etc. of

Indian Penal Code.

Page 1 of 42
Sir/Madam,
1. That, the Central Government on December 25, 2021 has given
permission to vaccinate the children in the age group between 15 to
18 years.
2. That few authorities are treating it as mandate.

3. It is an incorrect and completely wrong assumption. In fact, the

experimental corona vaccine is completely voluntary and in no
manner can be made compulsory either directly or indirectly.

4. That, in affidavit dated 08.10.2021 by Shri. Satyendra Singh,

Under Secretary Health Ministry of India before Hon’ble Bombay
High Court in Writ Petition No. 1820 of 2021, it is made clear that
the COVID-19 vaccination is completely voluntary for all citizens
of India and Ministry of Health and Family Welfare, Government
of India has not formulated or suggested any policies for
discrimination between citizens of India on the basis of their
vaccination status. The relevant paras of the affidavit read as under;

“9. That, it is further humbly submitted that the

directions and guidelines released by Government of
India and Ministry of Health and family Welfare, do
not entail compulsory or forcible vaccination against
COVID-19 disease implying that COVID-19
vaccination is completely voluntary for all citizens of
India. Ministry of Health and Family Welfare,
Government of India has not formulated or
suggested any policies for discrimination between
citizens of India on the basis of their vaccination
status.

10. That, it is duly advised, advertised and

communicated by MoHFW through various print and
Page 2 of 42
 social media platforms that all citizens should get
vaccinated, but this in no way implies that any person
can be forced to be vaccinated against her / his
wishes.

11. That, as per the existing guidelines, there is no

provisions for forcing any citizen to book appointment
for Covid Vaccination on Co-WIN or visiting Covid
Vaccination Centre for vaccination if a person above
the age of 18 years visits a Covid Vaccination Centre
by her / his choice for vaccination and asks for the
same, it implies that she / he is voluntarily coming to
the center to get the benefit of Covid Vaccination.”

5. That, recently on 28th November, 2021 in a Counter Affidavit filed

before Hon’ble Supreme Court by Dr. P.B.N. Prasad, working
as Joint Drugs Controller (India), Central Drugs Standard Control
Organization, Directorate General of Health Services, Ministry of
Health and Family Welfare, Government of India, it is once
again reiterated that vaccination is not linked to any benefits or
services. The relevant paragraph reads as under;

“64. In so far as the Petitioner's submissions

regarding Covid 19 vaccine being mandatory, as per
the Operational Guidelines document, COVID-19
vaccination is voluntary. However, it is emphasised
and encouraged that all individuals take vaccination
for public health and in his/ her interest as well as
public interest since in case of pandemic, an
individual's ill health has a direct effect on the
society. Covid-19 vaccination is also not linked to
any benefits or services. Therefore, any submissions

Page 3 of 42
 made by the Petitioner to the contrary, in so far as the
Answering Respondents are concerned, is denied.”

6. That, as per law, the vaccines cannot be mandated by any

authorities. [Registrar General, High Court of Meghalaya Vs.
State of Meghalaya 2021 SCC OnLine Megh 130, Re Dinthar
Incident Vs. State of Mizoram 2021 SCC OnLine Gau 1313,
Common Cause Vs. Union of India (2018) 5 SCC 1.

7. That, few authorities and school administration are threatening the

children and their parents to get vaccinated without which they will
not be allowed to attend the school or appear for exams.

8. That, above said act is not only illegal, but an offence under section
166, 188, 341, 342, 120(B), 34, 109 etc. of IPC.

9. That the vaccines are having fatal side effects in certain cases
which cannot be predicted by anyone in advance and also other
serious life long side effects.

10. Nine Reports on 12- 15 year olds who have died after a Covid-
19 injection. Reported to VAERS (US) by 27th August 2021:

10.1. Death of a 15 year old girl: Cardiac Arrest – 3 to 4 days after

second dose of Moderna injection. “I do not know the exact date
of the first or second Moderna Vaccine. I am the PICU attending
who cared for the patient after her cardiac arrest which we believe
was about 3-4 days after her second Moderna Vaccine”

https://medalerts.org/vaersdb/findfield.php?IDNUMBER=118791
8

10.2. Death of a 15 year old boy: Cardiac Failure – 2 days after Pfizer

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 injection “Heart Failure” Died 2 days after vaccination.
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=124257
3

10.3. Death of a 15 year old boy: Unexplained Death after Pfizer

injection “Unexplained death within 48 hours”
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=138290
6

10.4. Death of a 13 year old boy: Found deceased– 1 day after Pfizer
injection “Flu like symptoms for 2 days then was found deceased”
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=140684

10.5. Death of a 13 year old boy: Cardiac Arrest – 17 days after Pfizer
injection "Patient is a 13-year-old previously healthy male who was
admitted after out-of-hospital cardiac arrest found to be in the
context of large cerebellar haemorrhage secondary to brain lesion"
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=1431289

10.6. Death of a 13 year old boy: Unknown cause of death 3 days after
Moderna injection "Died three days after vaccine; 13 year old boy
dies three days after the Moderna vaccine"
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=1463061

10.7. Death of a 15 year old boy: 4 days after second dose of Pfizer
injection "Child collapsed on soccer field while playing soccer at a
local camp. CPR was initiated immediately. Patient had his second
covid vaccine on Sunday 7/18/2021. Died 7/22/2021"
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=1498080

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10.8. Death of a 13 year old girl: 26 days after Pfizer injection
"patient arrived in ventricular tachycardia via EMS, but responsive.
deteriorated to pulseless ventricular tachycardia, PEA and
ultimately death".
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=150525
0

10.9. Death of a 15 year old girl: Cardiac Arrest- 27 days after Pfizer
injection "A 15-year-old female patient received (COMIRNATY),
on 11 Jul 2021 07:30 (at the age of 15-year-old) as dose 1, single
for COVID-19 immunization. The patient died on 07Aug2021. An
autopsy was not performed. Cause of Death: Anoxia cerebral and
Cardiac arrest "
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=1592684

11. Vaccine Kills more children than Covid-19-A Columbia University

study finally gets the best estimate thus far on the Vaccine-induced
Fatality rate and survey says, the COVID ‘vaccine’ is at least 4
times, and as much as 10 time more fatal than the COVID-19 virus
itself.

https://www.generations.org/programs/2411
12. That, 18 European countries have banned the Covishield vaccines
due to death of youngsters.

Link: https://www.aljazeera.com/news/2021/3/15/which-
countries-have-halted-use-of-astrazenecas-covid-vaccine

13. Earlier attempts of false claims of vaccine safety by Authorities

are already exposed: -

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 13.1. That, in India few dishonest doctors like Dr. Randeep Guleria of
AIIMS, New Delhi, Dr. Soumya Swaminathan, Chief Scientist of
World Health Organization and others ran the false narratives that
the corona vaccines are completely safe and everyone should get
vaccinated.

13.2. Their narratives are proven to be false after several deaths due to
vaccines and also from the Report provided by the AEFI
Committee that the deaths are due to vaccines.

Link:https://drive.google.com/file/d/1_EZH9HhGknEHfbnPR8
jeam5OxGEjIbiE/view

13.3. The AEFI reports prove that, both the vaccines i.e. Covishield and
Covaxin are having fatal side effects in certain cases which cannot
be predicted by anyone in advance.

13.4. That as per media reports there are around 10,800 such deaths.

Link:https://drive.google.com/file/d/1uikc1a6_KDzUx7HNLrfw
aI1NJRt0D_YP/view

14. Suppression of numbers of vaccine deaths by the State

Authorities:-

14.1. In the UK 25 million doses of Covishield were administered and

1138 deaths post vaccination were reported. In India, 740 million
doses were administered and only 850 deaths were reported. How
is this possible? The answer is given by Justice Shri. D.Y.
Chandrachud, in a statement where he asked citizens and public
intellectuals to bring out the right data, as the state has a tendency
to suppress data.

14.2. That, in an interview dated 29 August, 2021 Hon'ble Justice D.Y.

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Chandrachud had said that the state is in habit of suppressing the information
and data regarding Covid-19 pandemic and it is the duty of the intellectual
citizen to expose their lies.

An excerpt from the said speech is as under;

“Supreme Court Judge Hon’ble Justice Dr. D. Y.

Chandrachud on 29th August 2021 said that the
State officer can spread lies, but citizens must be
vigilant. Public intellectuals have a duty to expose
lies of the state. Emphasizing the need for truth in a
democracy, he said the state can indulge in falsehood
and it was the duty of citizens to strengthen public
institutions and question the state to determine the
truth. In the context of the Covid-19 pandemic, we
see that there is an increasing trend of countries
across the world trying to manipulate data. Hence,
one cannot only rely on the state to determine the
truth”

Link: https://www.newindianexpress.com/thesundaystandard/2
021/aug/29/state-can-spread-lies-but-citizens-must-be-
vigilantsupreme-court-justice-dy-chandrachud-2351171.html

14.3. The dishonesty of the State authorities is ex-facie clear and can be
easily seen from following data. The National AEFI committee has
acknowledged that only 4 deaths have occurred from the vaccine.
However, the reply received from a small district in Kerala
(Mallapuram) district medical office has acknowledged that 11
people died only in Mallapuram due to side effects of vaccine
till 25.09.2021.

Link:https://drive.google.com/file/d/1taUq_VJmOAE4EeIuOH

Page 8 of 42
 Hcey768aIXs2yf/view

14.4. If based on the deaths occurred due to vaccination, proportionate

algorithm is applied or fair and transparent enquiry is done then the
figure of entire country will range in lacs of deaths due to
vaccines.

14.5. The National AEFI data states that, only 954 Deaths have occurred
post vaccination. However, as per the records compiled by
‘Awaken India Movement’ based on cases reported in media,
more than 10,800 deaths have occurred post vaccination. The other
deaths which are not reported in media are expected to be much
higher and the number might be in lacs.

Since several cases of heart attacks/cardiac arrest occurred due to

vaccines few months after vaccination or quite a long time after
vaccination, are neither reported nor counted by the AEFI
Committee. This exposes the lack of fairness on the part of the
state authorities.
Link for reported cases of 10,800 deaths is as under;

Link: https://drive.google.com/file/d/1uikc1a6_KDzUx7HNLrf
waI1NJRt0D_YP/view?usp=sharing

15. That thousands of honest doctors including the following who are
against vaccination of children.

(i) Dr. Sanjay Rai, AIIMS, New Delhi

(ii) Dr. Arvind Kumar Kushwaha

(iii) Dr. Amitav Banerjee

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 (iv) Dr. Maya Valecha

16. The concern expressed by the honest domain experts are

summarized as under;

i) Recently there is 400% of increase in death of school children

due to vaccination.

Link: https://theexpose.uk/2021/10/05/ons-data-shows-400-
percent-increase-male-children-deaths-since-they-had-covid-
vaccine/

ii) Young people are 40 Times More Likely to die from vaccines
than from COVID says major Japanese study.

Source: Greatgameindia
Link:https://greatgameindia.com/young-people-40-times-risk-
vaccines/

Published on: December 14, 2021

iii) Children are at Zero risk. Therefore, vaccinating them with a

vaccine which is developed in 4 months time and whose long and
short term side effects of which are not verified and which is not
duly approved, is pushing them to an unknown risk of death &
other side effect of vaccines.

iv) Around 80% and more children have already developed

antibodies. Such immunity is 13 to 27 times better than the vaccine
immunity.

Link: https://www.news9live.com/india/children-need-space-
not-vaccine-over-80-already-have-natural-immunity-
143095?infinitescroll=1

Page 10 of 42
v) Giving vaccine to Children with antibodies or natural immunity
in T-cell may cause serious damage to their bodies as seen
recently.

Study shows that, giving vaccines to the person with previous

Covid-19 infection is causing more harm than the disease itself.

An international survey 21 published in mid-March 2021 surveyed

2,002 people who had received a first dose of COVID-19 vaccine,
finding that those who had previously had COVID-19 experienced
“significantly increased incidence and severity” of side effects,
compared to those who did not have natural immunity.

The mRNA COVID-19 injections were linked to a higher

incidence of side effects compared to the viral vector-based
COVID-19 vaccines, but tended to be milder, local reactions.
Systemic reactions, such as anaphylaxis, flu-like illness and
breathlessness, were more likely to occur with the viral vector
COVID-19 vaccines.

“People with prior COVID-19 exposure were largely excluded

from the vaccine trials and, as a result, the safety and
reactogenicity of the vaccines in this population have not been
previously fully evaluated. For the first time, this study
demonstrates a significant association between prior COVID19
infection and a significantly higher incidence and severity of self-
reported side effects after vaccination for COVID-19.

Consistently, compared to the first dose of the vaccine, we found

an increased incidence and severity of self-reported side effects
after the second dose, when recipients had been previously exposed
to viral antigen.

Page 11 of 42
Link: https://www.mdpi.com/2075-1729/11/3/249/html

vi) There is no Scientific proof that Children can pass infection.

Only the dishonest doctors who are sponsored and funded by

Vaccine syndicates are running false narratives to promote the
100% vaccination of Children.

vii) Vaccinating the children with antibodies or natural immunity

will also be an offence under Section 409 of IPC as it will be a loss
of around Rs. 30,000 Crores of public money and wrongful gain of
vaccine companies.

viii) Children are not affected severely by Covid 19, as confirmed

by many prominent scientists. According to latest sero surveys, all
children in India have been exposed to it, and almost all of them
have acquired natural immunity which is robust and long lasting.

Children have better immunity against Covid 19. Many scientists

have attributed this to the fact that they have larger thymus glands
and to the absence of ACE2 receptors which impede the entry of
the virus into cells of the nasal passages, and therefore children
are not severely affected.

Our epidemiologists have time and again emphasized the

necessity of reopening schools without vaccination.
This information should be shared widely with parents, in order to
allay their fears and offer them reassurance:

● Why Don’t Kids Tend to Get as Sick From Covi 19?

https://www.smithsonianmag.com/science-nature/why-dont-
kids-tend-get-sick-covid-19-180978639/

● Article by eminent epidemiologist Amitav Banerjee

Page 12 of 42
 https://www.mjdrdypv.org/article.asp?issn=2589-
8302;year=2021;volume=14;issue=5;spage=477;epage=478;a
ulast=Banerjee;type=3

● What chances do children have against COVID-19? Is the

answer hidden within the thymus?

https://www.ncbi.nlm.nih.gov/labs/pmc/articles/PMC7550201

● The National Technical Advisory Group on Immunisati

on advised the Centre that Covid-19 vaccination for children is
not a priority.

https://www.indiatoday.in/coronavirus-outbreak/vaccine-
updates/story/covid-19-vaccine-for-children-not-a-priority-ntagi-
centre-1890416-2021-12-21

ix) There is no availability of long term safety data for Covid-19

vaccines, as the vaccines were developed fast, using a new
experimental technology and they are being used under Emergency
Use Authorization, which means that this is an ongoing global
clinical trial pending full FDA approval. Whereas, there are safer
methods to mitigate Covid-19, such as the AYUSH approved
Ayurvedic protocol, Anandaiah’s protocol and Homeopathic
protocol, Naturopathy etc. for Covid-19.

https://drive.google.com/file/d/1Hl76y7BwU8i57z5Z3xk8XbPvM
zG366II/view?usp=sha ring

x) Adverse effects including deaths from these gene based

experimental Covid-19 vaccines are being reported from across
the world. Chances that DNA Technology based vaccine have
carcinogenic life-threatening side effects are highlighted in The
Washington Times article. The first children’s vaccine in

Page 13 of 42
India ZyCov-D, is DNA based.

● https://m.washingtontimes.com/news/2021/oct/28/applying
-brakes-on-warp-speed-co vid-19-vaccination
● https://medalerts.org/vaersdb/findfield.php?TABLE=ON&G
ROUP1=AGE&EVENTS
=ON&VAX=COVID19&VAXTYPES=COVID-
19&STATE=NOTFR&WhichAge=range&LOWAGE=12&HIG
HAGE=18
● VAERS-
USA Covid Vaccine Data Show Surge in Reports of Serious
Injuries, as 5-Year-Olds Start Getting Shots
https://childrenshealthdefense.org/defender/vaers-cdc-covid-
vaccine-data-injuries-5-year-olds/

To see how devastatingly damaging and life-threatening the side

effects of Covid-19 vaccines are, please follow these steps > Go
to www.vigiaccess.org > Scroll to the bottom of the page and click
– ‘I understand’ > Click ‘Search Database’ and type in ‘Covid-19
Vaccine’ and click Search > Click ADRs then click on each ADR
for its details.

xi) Dr. Robert Malone- Virologist & Immunologist, Architect of

mRNA Vaccine Technology - Warns parents of the dangers of the
experimental jab.
https://www.bitchute.com/video/DDloeBLBlBM1

xii) Omicron is a blessing and serving as natural vaccine.

Link: https://www.outlookindia.com/website/story/india-news-
with-mild-symptoms-omicron-is-probably-natural-vaccine-top-
scientists-doctors/406227

Page 14 of 42
(xiii) The inoculations were tested only for a few months and only
short-term adverse effects could be obtained, it is questionable how
well even these short-term effects obtained from the clinical trials
reflect the short-term effects from the initial mass inoculation
results reported in VAERS.

Link:https://www.sciencedirect.com/science/article/pii/S221475
002100161X

(xiv) When overall mortality rates are nearly 0% percent for

children, and we don’t have long term studies, universal drive for
vaccinating all comorbid children should NOT be started.

(xv) On one hand, our children have acquired immunity post Covid
and on the other hand, these experimental vaccines wherever in the
world they are rolled out, are not found to be safe enough, so it is
totally irresponsible and unethical to go ahead with any vaccine
roll out for children.

According to new study, teenage boys are six times more likely to
suffer heart problems from Covid-19 vaccine than to be
hospitalised from Covid.

“The margin of benefit, based primarily on a health perspective, is

considered too small to support advice on a universal programme
of vaccination of otherwise healthy 12 to 15-year-old children at
this time. As longer-term data on potential adverse reactions
accrue, greater certainty may allow for a reconsideration of the
benefits and harms. Such data may not be available for several
months.”

xvi) That the conspiracy theories and narrative run by Dr. Randeep
Guleria and others has proven to be false several times. Recently in

Page 15 of 42
 Harvard Business School, UK there was a Covid-19 outbreak even
when 96% students were vaccinated. The positivity rate of
outbreak was 12 times higher than that of rest of Harvard.

Link: https://theexpose.uk/2021/10/01/harvard-business-school-
shuts-down-after-massive-covid-19-outbreak-despite-almost-
all-students-being-fully-vaccinated/

xvii) The record also shows and it is observed by Division Bench

of Hon’ble High Court that the vaccinated person can get infected
with corona and he can also be a ‘super spreader’. [Madan Mili
Vs. UOI 2021 SCC OnLine Gau 1503].

Many vaccinated people died due to corona and also due to side
effects of vaccines.

xviii) The vested interest of corrupt members of National Task

Force, ICMR, AIIMS, PHFI, DGHS, NTAGI, NAEFI Committee,
ITSU, DCGI, CDSCO etc. are ex-facie clear and also exposed in
the notice for proceedings under Contempt & Section 80 of C.P.C.
dated 23.09.2021 issued to Hon’ble Health Minister Shri. Mansukh
Mandaviya.

A copy of said notice is annexed herewith and it is also available at

following link.

Link:https://drive.google.com/file/d/160ksZL71vi9rgxstf21_-
dyf9jDVAfvf/view

xix) Under these circumstances, the act of Shri. V.G. Somani, the
Drug Controller General of India in granting Emergency Use
Authorization to vaccine for children is itself sufficient to draw an
inference of his corrupt motives and ulterior purposes.

17. Law of Informed Consent of children:

Page 16 of 42
17.1. That the vaccines are only experimental vaccines as they are given
Emergency Use Authorization and are still at clinical trial stage.

Actual vaccines require around 8 to 10 years or more for complete

study of the side effects amongst children.

17.2. The children cannot be given vaccines or any treatment without

written consent of their parents.

17.3. In Master Haridaan Kumar Vs. Union of India 2019 SCC

OnLine Del 11929, it is ruled as under;

“14. The contention that indication of the side effects

and contraindications in the advertisement would
discourage parents or guardians from consenting to
the MR campaign and, therefore, the same should be
avoided, is unmerited. The entire object of issuing
advertisements is to ensure that necessary
information is available to all parents/guardians in
order that they can take an informed decision. The
respondents are not only required to indicate the
benefits of the MR vaccine but also indicate the side
effects or contraindications so that the
parents/guardians can take an informed decision
whether the vaccine is to be administered to their
wards/children.

15. In view of the above, it is directed as under:

(4) MR vaccines will not be administered to those

students whose parents/guardians have declined to
give their consent. The said vaccination will be
administered only to those students whose parents

Page 17 of 42
 have given their consent either by returning the
consent forms or by conforming the same directly to
the class teacher/nodal teacher and also to students
whose parents/guardians cannot be contacted despite
best efforts by the class teacher/nodal teacher and
who have otherwise not indicated to the contrary.

(1) Directorate of Family Welfare shall issue quarter

page advisements in various newspapers as indicated
by the respondents, namely, The Hindustan Times, The
Times of India, The Hindu, The Pioneer, The Indian
Express, Delhi Tribune, Mail Today, The Asian Age,
Navbharat Times, Dainik Jagran, Punjab Kesari,
Hindustan, Amar Ujala, Navodaya Times, Hamara
Samaj, Pratap, Daur-e-Jadeed, Jathedar, Jan Ekta.
The advertisements shall also indicate that the
vaccination shall be administered with Auto Disable
Syringes to the eligible children by Auxiliary Nurse
Midwifery. The advertisement shall also clearly
indicate the side effects and contraindications as may
be finalised by the Department of Preventive
Medicine, All India Institute of Medical Sciences.”

17.4. That the provisions of Universal Declaration on Bioethics and

Human Rights, 2005 also mandate for informed consent.
Relevant Articles reads thus;

“Article 3 – Human dignity and human rights

1. Human dignity, human rights and fundamental

freedoms are to be fully respected.

2. The interests and welfare of the individual should

Page 18 of 42
have priority over the sole interest of science or
society.

Article 6 – Consent

1. Any preventive, diagnostic and therapeutic

medical intervention is only to be carried out with
the prior, free and informed consent of the person
concerned, based on adequate information. The
consent should, where appropriate, be express and
may be withdrawn by the person concerned at any
time and for any reason without disadvantage or
prejudice.

2. Scientific research should only be carried out with

the prior, free, express and informed consent of the
person concerned. The information should be
adequate, provided in a comprehensible form and
should include modalities for withdrawal of consent.
Consent may be withdrawn by the person concerned
at any time and for any reason without any
disadvantage or prejudice. Exceptions to this
principle should be made only in accordance with
ethical and legal standards adopted by States,
consistent with the principles and provisions set out in
this Declaration, in particular in Article 27, and
international human rights law.

3. In appropriate cases of research carried out on a

group of persons or a community, additional
agreement of the legal representatives of the group or
community concerned may be sought. In no case

Page 19 of 42
should a collective community agreement or the
consent of a community leader or other authority
substitute for an individual’s informed consent.

Article 7 – Persons without the capacity to consent

In accordance with domestic law, special protection is

to be given to persons who do not have the capacity to
consent:

(a) authorization for research and medical practice

should be obtained in accordance with the best
interest of the person concerned and in accordance
with domestic law. However, the person concerned
should be involved to the greatest extent possible in
the decision-making process of consent, as well as
that of withdrawing consent;

(b) research should only be carried out for his or her

direct health benefit, subject to the authorization and
the protective conditions prescribed by law, and if
there is no research alternative of comparable
effectiveness with research participants able to
consent. Research which does not have potential
direct health benefit should only be undertaken by way
of exception, with the utmost restraint, exposing the
person only to a minimal risk and minimal burden
and, if the research is expected to contribute to the
health benefit of other persons in the same category,
subject to the conditions prescribed by law and
compatible with the protection of the individual’s
human rights. Refusal of such persons to take part in

Page 20 of 42
research should be respected.

Article 8 – Respect for human vulnerability and

personal integrity

In applying and advancing scientific knowledge,

medical practice and associated technologies, human
vulnerability should be taken into account. Individuals
and groups of special vulnerability should be
protected and the personal integrity of such
individuals respected.

Article 16 – Protecting future generations

The impact of life sciences on future generations,

including on their genetic constitution, should be
given due regard.

Application of the principles

Article 18 – Decision-making and addressing

bioethical issues

1. Professionalism, honesty, integrity and

transparency in decision-making should be promoted,
in particular declarations of all conflicts of interest
and appropriate sharing of knowledge. Every
endeavour should be made to use the best available
scientific knowledge and methodology in addressing
and periodically reviewing bioethical issues.

2. Persons and professionals concerned and society as

a whole should be engaged in dialogue on a regular
basis.

Page 21 of 42
 3. Opportunities for informed pluralistic public
debate, seeking the expression of all relevant
opinions, should be promoted.”

18. No one can ask the parents their reason for not taking
experimental corona vaccines:

18.1. That, Supreme Court in Common Cause Vs. Union of India

(2018) 5 SCC 1, it is ruled as under;

“517. The entitlement of each individual to a

dignified existence necessitates constitutional
recognition of the principle that an individual
possessed of a free and competent mental state
is entitled to decide whether or not to accept
medical treatment. The right of such an
individual to refuse medical treatment is
unconditional. Neither the law nor the
Constitution compel an individual who is
competent and able to take decisions, to
disclose the reasons for refusing medical
treatment nor is such a refusal subject to the
supervisory control of an outside entity;

202.9. Right to life and liberty as envisaged

under Article 21 of the Constitution is
meaningless unless it encompasses within its
sphere individual dignity. With the passage of
time, this Court has expanded the spectrum of
Article 21 to include within it the right to live
with dignity as component of right to life and
liberty.

Page 22 of 42
 306. In addition to personal autonomy, other
facets of human dignity, namely, “self-
expression” and “right to determine” also
support the argument that it is the choice of the
patient to receive or not to receive treatment.”

18.2. In Montgomery Vs. Lanarkshire Health Board [2015] UKSC

11, it is ruled as under;

“77. These developments in society are reflected in

professional practice. The court has been referred in
particular to the guidance given to doctors by the
General Medical Council, who participated as
interveners in the present appeal. One of the
documents currently in force (Good Medical Practice
(2013)) states, under the heading “The duties of a
doctor registered with the General Medical
Council”:

“Work in partnership with patients. Listen to, and

respond to, their concerns and preferences. Give
patients the information they want or need in a way
they can understand. Respect patients’ right to reach
decisions with you about their treatment and care.”

78. Another current document (Consent: patients and

doctors making decisions together (2008)) describes a
basic model of partnership between doctor and
patient:

“The doctor explains the options to the patient,

setting out the potential benefits, risks, burdens and
side effects of each option, including the option to

Page 23 of 42
have no treatment. The doctor may recommend a
particular option which they believe to be best for the
patient, but they must not put pressure on the patient
to accept their advice. The patient weighs up the
potential benefits, risks and burdens of the various
options as well as any non-clinical issues that are
relevant to them. The patient decides whether to
accept any of the options and, if so, which one.”
(para 5)

In relation to risks, in particular, the document

advises that the doctor must tell patients if treatment
might result in a serious adverse outcome, even if the
risk is very small, and should also tell patients about
less serious complications if they occur frequently
(para 32). The submissions on behalf of the General
Medical Council acknowledged, in relation to these
documents, that an approach based upon the informed
involvement of patients in their treatment, rather than
their being passive and potentially reluctant
recipients, can have therapeutic benefits, and is
regarded as an integral aspect of professionalism in
treatment.

80. In addition to these developments in society and in

medical practice, there have also been developments
in the law. Under the stimulus of the Human Rights
Act 1998, the courts have become increasingly
conscious of the extent to which the common law
reflects fundamental values. As Lord Scarman pointed
out in Sidaway’s case, these include the value of self-

Page 24 of 42
determination (see, for example, S (An Infant) v S
[1972] AC 24, 43 per Lord Reid; McColl v
Strathclyde Regional Council 1983 SC 225, 241;
Airedale NHS Trust v Bland [1993] AC 789, 864 per
Lord Goff of Chieveley). As well as underlying aspects
of the common law, that value also underlies the right
to respect for private life protected by article 8 of the
European Convention on Human Rights. The resulting
duty to involve the patient in decisions relating to her
treatment has been recognised in judgments of the
European Court of Human Rights, such as Glass v
United Kingdom (2004) EHRR 341 and Tysiac v
Poland (2007) 45 EHRR 947, as well as in a number
of decisions of courts in the United Kingdom. The
same value is also reflected more specifically in other
international instruments: see, in particular, article 5
of the Convention for the Protection of Human Rights
and Dignity of the Human Being with regard to the
Application of Biology and Medicine: Convention on
Human Rights and Biomedicine, concluded by the
member states of the Council of Europe, other states
and the European Community at Oviedo on 4 April
1997.

82. In the law of negligence, this approach entails a

duty on the part of doctors to take reasonable care to
ensure that a patient is aware of material risks of
injury that are inherent in treatment. This can be
understood, within the traditional framework of
negligence, as a duty of care to avoid exposing a
person to a risk of injury which she would otherwise

Page 25 of 42
have avoided, but it is also the counterpart of the
patient’s entitlement to decide whether or not to incur
that risk. The existence of that entitlement, and the
fact that its exercise does not depend exclusively on
medical considerations, are important. They point to a
fundamental distinction between, on the one hand, the
doctor’s role when considering possible investigatory
or treatment options and, on the other, her role in
discussing with the patient any recommended
treatment and possible alternatives, and the risks of
injury which may be involved.

83. The former role is an exercise of professional skill

and judgment: what risks of injury are involved in an
operation, for example, is a matter falling within the
expertise of members of the medical profession. But it
is a non sequitur to conclude that the question
whether a risk of injury, or the availability of an
alternative form of treatment, ought to be discussed
with the patient is also a matter of purely professional
judgment. The doctor’s advisory role cannot be
regarded as solely an exercise of medical skill without
leaving out of account the patient’s entitlement to
decide on the risks to her health which she is willing
to run (a decision which may be influenced by non-
medical considerations). Responsibility for
determining the nature and extent of a person’s rights
rests with the courts, not with the medical professions.

87. The correct position, in relation to the risks of

injury involved in treatment, can now be seen to be

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substantially that adopted in Sidaway by Lord
Scarman, and by Lord Woolf MR in Pearce, subject to
the refinement made by the High Court of Australia in
Rogers v Whitaker, which we have discussed at paras
77-73. An adult person of sound mind is entitled to
decide which, if any, of the available forms of
treatment to undergo, and her consent must be
obtained before treatment interfering with her bodily
integrity is undertaken. The doctor is therefore under
a duty to take reasonable care to ensure that the
patient is aware of any material risks involved in any
recommended treatment, and of any reasonable
alternative or variant treatments. The test of
materiality is whether, in the circumstances of the
particular case, a reasonable person in the patient’s
position would be likely to attach significance to the
risk, or the doctor is or should reasonably be aware
that the particular patient would be likely to attach
significance to it.

89. Three further points should be made. First, it

follows from this approach that the assessment
of whether a risk is material cannot be reduced to
percentages. The significance of a given risk is likely
to reflect a variety of factors besides its magnitude:
for example, the nature of the risk, the effect which its
occurrence would have upon the life of the patient, the
importance to the patient of the benefits sought to be
achieved by the treatment, the alternatives available,
and the risks involved in those alternatives. The
assessment is therefore fact-sensitive, and sensitive

Page 27 of 42
 also to the characteristics of the patient.

90. Secondly, the doctor’s advisory role involves

dialogue, the aim of which is to ensure that the patient
understands the seriousness of her condition, and the
anticipated benefits and risks of the proposed
treatment and any reasonable alternatives, so that she
is then in a position to make an informed decision.
This role will only be performed effectively if the
information provided is comprehensible. The doctor’s
duty is not therefore fulfilled by bombarding the
patient with technical information which she cannot
reasonably be expected to grasp, let alone by
routinely demanding her signature on a consent
form.

116. As NICE (2011) puts it, “Pregnant women should

be offered evidence-based information and support to
enable them to make informed decisions about their
care and treatment” (para 1.1.1.1). Gone are the days
when it was thought that, on becoming pregnant, a
woman lost, not only her capacity, but also her right
to act as a genuinely autonomous human being.”

19. Liability of School & other authorities under Criminal & Civil
Law:

19.1. That Hon’ble High Court in Registrar General, High Court

of Meghalaya Vs. State of Meghalaya 2021 SCC OnLine Megh
130, it is ruled as under;

“………
Thus, by use of force or through deception if an

Page 28 of 42
unwilling capable adult is made to have the flu
vaccine would be considered both a crime and tort or
civil wrong, as was ruled in Airedale NHS Trust v
Bland reported at 1993 AC 789 = (1993) 2 WLR 316
= (1993) 1 All ER 821, around thirty years (30) ago.
Thus, coercive element of vaccination has, since the
early phases of the initiation of vaccination as a
preventive measure against several diseases, have
been time and again not only discouraged but also
consistently ruled against by the Courts for over
more than a century.
In this context, around one hundred and seven (107)
years ago, in Schloendroff v Society of New York
Hospitals reported at (1914) 211 NY 125 = 105 NE
92; 1914 NY Justice Cardozo ruled that „every human
being of adult years and sound mind has a right to
determine what shall be done with their body‟.

This finds mention in decisions of the European

Commission and Court of Human Rights [X vs.
Netherlands of 1978 (decision rendered on 4th
December, 1978); X vs. Austria of 1979 (decision
rendered on 13th December, 1979)] which has
become truer in the present times across the world
than ever before. Compulsorily administration of a
vaccine without hampering one‟s right to life and
liberty based on informed choice and informed
consent is one thing. However, if any compulsory
vaccination drive is coercive by its very nature and
spirit, it assumes a different proportion and
character.

Page 29 of 42
 However, vaccination by force or being made
mandatory by adopting coercive methods, vitiates the
very fundamental purpose of the welfare attached to
it.”

19.2. All authorities are bound to ensure that they should not be part of
conspiracy to the offences committed by the authorities.

19.3. The act of omission on the part of any authority also make them
liable for prosecution as that of the main offender. Hon’ble
Supreme Court in State of Odisha Vs. Pratima Mohanty Etc.
2021 SCC OnLine SC 1222.

19.4. Every person joining the conspiracy is liable.

In Raman Lal Vs. State of Rajasthan 2000 SCC OnLine Raj

226, has ruled that;

“Conspiracy – I.P.C. Sec. 120 (B) – Apex court made

it clear that an inference of conspiracy has to be
drawn on the basis of circumstantial evidence only
because it becomes difficult to get direct evidence on
such issue – The offence can only be proved largely
from the inference drawn from acts or illegal
ommission committed by them in furtherance of a
common design – Once such a conspiracy is proved,
act of one conspirator becomes the act of the others –
A Co-conspirator who joins subsequently and
commits overt acts in furtherance of the conspiracy
must also be held liable – Proceeding against accused
cannot be quashed.”

20. Under these circumstances it is clear that the Authorities, Principal,

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 School Management, Ministers etc., who are promoting vaccines
should resist and desist from doing any act which is violative of the
mandates of the law and constitution.

21. Needless to mention here that, any authority or school staff are not
supposed to follow any unlawful or unconstitutional orders by the
senior Government officials or even by the courts if constitutional
provisions are vitiated. If anyone follows unconstitutional and
illegal orders, then he should be held guilty of offence even if the
order was that of the Court. [Nandini Satpathy Vs. P.L.Dani
(1978) 2 SCC 424].

22. I hope and sincerely urge everyone that, please don’t take any
decision or indulge in any negligence, carelessness or show any
over enthusiasm that might put the life of children in danger.

Children are our future. They should be protected at any cost.

23. Once the children are given experimental corona vaccines, then
there is no process for reversing the effect, if these vaccines prove
to be harmful, as had happened recently regarding thousands of
vaccine deaths, paralysis, blood clotting, heart inflammation,
blindness, deafness, myocarditis.

24. That the vaccine manufacturer and the kingpin of Vaccine

Syndicate Mr. Bill Gates is a pervert man and has some
psychological issues about children as already proven to have
involved in murders of several children in India.

24.1. 72nd Parliamentary Committee Report regarding vaccine murder of

8 children in India by Bill Gates in conspiracy with officials of
ICMR & DGHS. The said report is held to be legally admissible by
the Constitution Bench of the Supreme Court of India

Page 31 of 42
 in Kalpana Mehta Vs. Union of India 2018(7) SCC 1.

24.2. A Complaint is filed by the Secretary General of Human Right

Security Council asking immediate F.I.R. is taken note by the
Prime Minister of India and directions have been issued
on 29.12.2021 to Health Ministry.

Copy of Complaint by the Secretary General of Human Right

Security Council is available at link below:

Link: https://drive.google.com/file/d/1oereNdDnpuJYuTzy8XZ
J17YNBcIva4GH/view

Copy of the letter sent by the office of Prime Minister is available

at Link:

Link: https://drive.google.com/file/d/1IBnfq25AYtYCnLrJBM
0xMTTViEHd-cyp/view

24.3. That the same accused Bill Gates through his program of
increasing polio doses amongst children in India have killed many
children and made many children permanently disabled. Later said
program was stopped by the Government.

Link: https://www.thehindu.com/news/cities/Delhi/vaccine-
induced-paralysis-calls-for-action-says-
study/article24740588.ece

24.4. Parliamentary Committee’s 72nd report dated 30th August,

2013 exposing corruption by ICMR and other officials
involved in conspiracy to help vaccine syndicate sponsored by
Bill and Melinda Gates Foundation and also responsible for
offences of murder of female children. Supreme Court
judgment upholded the evidentiary value of Report

Page 32 of 42
Parliamentary Committee.

a) That, the ‘Toxic Philanthropist’ and ‘Vaccine Syndicate’

Kingpin Mr. Bill Gates, through his foundation ‘Bill &
Melinda Gates Foundation’ had sponsored a vaccine trial in
India through ‘Program for Appropriate Technology in
Health (PATH)’. In the said program, they had malafidely,
unauthorizedly, illegally and unlawfully conducted trials of
HPV vaccines i.e. Human Papilloma Virus (HPV) on female
school children in India.

b) The said program was funded by Bill & Melinda Gates

Foundation.

c) Said illegal act has resulted into death of 8 female

children in states of Gujarat and Andhra Pradesh in the year
2010.

d) Government of India constituted a parliamentary

committee of 31 members to enquire the matter.

e) The committee submitted its 72nd report on 30th August,

2013 in Rajya Sabha.

f) In the said Enquiry Report, it is specifically concluded

that the program was to serve the ulterior, commercial
interests of vaccine manufacturer to include the said vaccine
in universal immunization programme which would have
generated windfall profit for the manufacturer(s) by way of
automatic sale year after year, without any promotional or
marketing expenses.

g) The committee also concluded that the officers of Indian

Council of Medical Research (ICMR), in an unauthorized

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 manner, had signed Memorandum of Understanding (MoU)
in 2007 even before the vaccines were approved for use in
the country, which actually happened in the year 2008.

The decision of ICMR of committing itself to promote the

drug for inclusion in the Universal Immunization
Programme (UIP) without an independent study regarding
its utility was strongly objected. It was suggested that the
investigation should be done by the premier investigation
agency i.e. C.B.I. and appropriate legal action be taken
against them.

h) A copy of 72nd Report of Parliamentary Committee dated

30.08.2013 and it is available at following link.

Link:http://164.100.47.5/newcommittee/reports/EnglishC
ommittees/Committee%20on%20Health%20and%20Fa
mily%20Welfare/72.pdf
24.5. Recommendation of the Parliamentary Committee asking for
investigation and legal action against Bill Gates and officials of
ICMR.
a) That the recommendations are as under;

“7.13. Coming to the instant case, it is established that

PATH by carrying out the clinical trials for HPV vaccines in
Andhra Pradesh and Gujarat under the pretext of
observation/ demonstration project has violated all laws and
regulations laid down for clinical trials by the Government.
While doing so, its sole aim has been to promote the
commercial interests of HPV vaccine manufacturers who
would have reaped windfall profits had PATH been
successful in getting the HPV vaccine included in the UIP of

Page 34 of 42
the Country. This is a serious breach of trust by any entity as
the project involved life and safety of girl children and
adolescents who were mostly unaware of the implications of
vaccination. The violation is also a serious breach of
medical ethics. This act of PATH is a clear cut violation of
the human rights of these girl children and adolescents. It
also deems it an established case of child abuse. The
Committee, therefore, recommends action by the
Government against PATH. The Committee also desires that
the National Human Rights Commission and National
Commission for Protection of Children Rights may take up
this matter from the point of view of the violation of human
rights and child abuse. The National Commission for
Women should also suomotu take cognizance of this case as
all the poor and hapless subjects are females.

7.14. The Ministry of Health and Family Welfare should

without wasting time report the violations indulged in by
PATH to international bodies like WHO and UNICEF so as
to ensure that appropriate remedial action is initiated by
these agencies worldwide.

7.15. The Committee also desires that the Ministry of

Health and Family Welfare may take up the matter through
the Ministry of External Affairs with the US Government so
as to ensure that appropriate action is taken against PATH
under the laws of its country of origin in case of any
violations of laws there.

6.26. The Committee observes that the wrongful use of the

NRHM logo for a project implemented by a private, foreign
agency as well as the identification of this project with the

Page 35 of 42
UIP has adversely affected and damaged the credibility of
the programme as well as that of the NRHM. The
Committee, therefore, recommends that such practices of
diverting public funds for advancing interests of a private
agency should never be allowed in future. The Committee
strongly recommends that strict action should be taken
against those officials responsible for such lapses.

6.27. Besides, the Committee notes that no information had

been provided to Indian authorities about funding of the
project except that it was reportedly funded by Bill and
Melinda Gates Foundation and that the vaccines had been
donated by the manufacturers. The information regarding
financial investments of ICMR and State Governments in the
project was not provided, though the States clearly provided
cold chain and manpower for immunization. The Committee,
accordingly, observes that it might have been more prudent
if the National Technical Advisory group on Immunization
(NTAGI) had been brought into the picture right in the
beginning to review and give its views on the study prior to
its approval and implementation.

7.11. The Committee is concerned that if PATH can set up

an office in India so easily without getting the required
mandatory approvals/permissions, then individuals and
entities inimical to the interest of the country can do the
same. The Committee expresses its concern that paper and
shell companies can be easily registered in many
jurisdictions and then set up a place of business in India as
“Liaison offices” with no questions being asked. It is
surprising that security and intelligence agencies did not

Page 36 of 42
raise an eyebrow on the way a foreign entity entered India
virtually incognito through the backdoor. The Committee
desires that such incidents should not be allowed in future.
The Government should tighten the rules lest one day foreign
citizens, with deep roots in organizations/nations inimical to
India, set up offices in the country to engage in anti-national
and/or unlawful activities.

6.29. Considering the above lapses and irregularities

committed by PATH during the course of conducting the
trials on hapless tribal children in Andhra Pradesh and
Gujarat, the Committee is convinced that the authorities
concerned did not exercise due diligence in scrutinizing the
publicity material of PATH. Blurring the distinction between
the UIP and PATH project due to the involvement of the
State Governments in the project and ignoring the financial
contribution of ICMR and the State Governments are very
serious issues. The Committee, therefore, recommends that
the Ministry should investigate into the above acts of
omissions and commissions and take necessary action
against those who are found responsible for breach of rules
and regulations.

2.5. The Committee finds the entire matter very intriguing

and fishy. The choice of countries and population groups;
the monopolistic nature, at that point of time, of the product
being pushed; the unlimited market potential and
opportunities in the universal immunization progammes of
the respective countries are all pointers to a well planned
scheme to commercially exploit a situation. Had PATH been
successful in getting the HPV 4 vaccine included in the

Page 37 of 42
universal immunization programme of the concerned
countries, this would have generated windfall profit for the
manufacturer(s) by way of automatic sale, year after year,
without any promotional or marketing expenses. It is well
known that once introduced into the immunization
programme it becomes politically impossible to stop any
vaccination. To achieve this end effortlessly without going
through the arduous and strictly regulated route of clinical
trials, PATH resorted to an element of subterfuge by calling
the clinical trials as “Observational Studies” or
“Demonstration Project” and various such expressions.
Thus, the interest, safety and well being of subjects were
completely jeopardized by PATH by using self-determined
and self-servicing nomenclature which is not only highly
deplorable but a serious breach of law of the land. The
Committee is not aware about the strategy followed by
PATH in the remaining three countries viz. Uganda,
Vietnam and Peru. The Government should take up the
matter with the Governments of these countries through
diplomatic channels to know the truth of the matter and take
appropriate necessary action, accordingly. The Committee
would also like to be apprised of the responses of these
countries in the matter.

3.18. The Committee feels that there was serious dereliction

of duty by many of the Institutions and individuals involved.
The Committee observes that ICMR representatives, instead
of ensuring highest levels of ethical standards in research
studies, apparently acted at the behest of the PATH in
promoting the interests of manufacturers of the HPV
Vaccine. 7 3.19 It was unwise on the part of ICMR to go in

Page 38 of 42
the PPP mode with PATH, as such an involvement gives rise
to grave Conflict of Interest. The Committee takes a serious
view of the role of ICMR in the entire episode and is
constrained to observe that ICMR should have been more
responsible in the matter. The Committee strongly
recommends that the Ministry may review the activities of
ICMR functionaries involved in PATH project.

6.10. The Committee notes that once this matter was taken
up by it, the Government appointed an Inquiry Committee on
15 April, 2010 to inquire into ‘alleged irregularities in the
conduct of the studies using HPV vaccines by PATH in
India’. The Committee has noted the serious conflict of
interest of members of this Inquiry Committee with the
subject matter. The Committee, therefore, strongly
deprecates the Government for appointing a committee to
inquire into such a serious matter in such a casual manner
even without ascertaining as to whether any of the members
of the said Inquiry Committee were having any conflict of
interest with the subject matter of inquiry.

6.17. The Committee, accordingly, concludes that most, if

not all consent forms, were carelessly filled-up and were
incomplete and inaccurate. The full explanation, role,
usefulness and pros and cons of vaccination had not been
properly communicated to the parents/guardians. The
Committee observes that there is a gross violation of the
consent and legal requirement of consent which had been
substantiated by the experts. The Committee takes a serious
view of the violations and strongly recommends that on the
basis of the above facts, PATH should be made accountable

Page 39 of 42
 and the Ministry should take appropriate action in the
matter including taking legal action against it for breach of
various laws of the land and possible violations of laws of
the Country of its origin.

6.29. Considering the above lapses and irregularities

committed by PATH during the course of conducting the
trials on hapless tribal children in Andhra Pradesh and
Gujarat, the Committee is convinced that the authorities
concerned did not exercise due diligence in scrutinizing the
publicity material of PATH. Blurring the distinction between
the UIP and PATH project due to the involvement of the
State Governments in the project and ignoring the financial
contribution of ICMR and the State Governments are very
serious issues. The Committee, therefore, recommends that
the Ministry should investigate into the above acts of
omissions and commissions and take necessary action
against those who are found responsible for breach of rules
and regulations.”

b) That, the evidentiary value and legality of the above report and
its use as per section 74 of the Evidence Act is again confirmed by
the Constitution Bench of the Supreme Court in the case of
Kalpana Mehta Vs. Union Of India (2018) 7 SCC 1.

The above order is passed after hearing the Bill Gates entity
‘PATH’.

c) Even otherwise, as per Section 35 of the Evidence Act, and as

per the law laid down by the Full Bench in P.C. Reddiar’s case
AIR 1972 SC 608, it is clear that the findings of compensation to
public can be based on above said report.

Page 40 of 42
 d) On the basis of the findings of above mentioned Committee and
considering all other material available on record, it is sufficient to
draw a conclusion that the accused Bill Gates is a habitual
offender and he, along with his organized crime syndicate, needs
to be punished forthwith by constituting a special court or Tribunal
headed by former CJI R.M. Lodha or any other deserving Judge
with special provisions of disposing of each claim within 2 months
fixed as maximum time limit and allowing only one appeal before
a special Bench of the Supreme Court and that too be decided
within 3 weeks of filing.

25. Concluding Paragraph:

(i) Vaccinating children is an unscientific and illogical decision;

(ii) No authority can impose any condition to get vaccinated;

(iii) Forcing to get vaccinated to avail certain services is a civil

wrong and criminal offence punishable under Section 166, 188,
341, 342, 109, 323, 336, 511, 115, 120 (B), 34, 52 etc. of IPC and
Section 51(b), 55 of Disaster Management Act, 2005;

(iv) If any children die due to vaccination then concerned doctors

& authorities will be liable for charge of murder punishable under
Section 302 of IPC;

(v) Except the written consent of parents, the children should not
be vaccinated. Informed consent of parents is mandatory;

(vi) The Doctors or public authorities promoting vaccination are

bound to explain and publish the death causing and other side
effects of vaccines;

Page 41 of 42
(vii) Without such publication and without giving full information
if any children are vaccinated, then it is an offence of cheating
punishable under Section 420, 120 (B) & 34 of IPC;

In the said prosecution, victim parents can demand compensation

of any amount without paying court fee, by invoking section 357
(3) of Code of Criminal Procedure Code;

(viii) As per section 120 (B) all the school authorities, Principal,
Doctors, Nurses, ASHA (Accredited Social Health
Activist) workers etc. will be equally responsible for all the
offences for their act of commission and omission. [Raman Lal
Vs. State of Rajasthan 2020 SCC OnLine Raj 226, State of
Odisha Vs. Pratima Mohanty 2021 SCC OnLine SC 1222]

(ix) As per section 52 of IPC nothing can be said to be done in

good faith if it is not done with due care and caution.

Yours sincerely

Adv. Dipali N. Ojha

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